HealthBlawg :: David Harlow's Health Care Law Bloghttps://healthblawg.com
Current developments in health care law and policy together with the observations and analysis of David Harlow, principal of The Harlow Group LLC, a health care law and consulting firm based near Boston, Massachusetts.Tue, 06 Feb 2018 13:11:10 +0000en-UShourly1David HarlowDavid HarlowCreative Commons Attribution-Share Alike 3.0Current developments in health care law and policy together with the observations and analysis of David Harlow, principal of The Harlow Group LLC, a health care law and consulting firm based near Boston, Massachusetts.Current developments in health care law and policy together with the observations and analysis of David Harlow, principal of The Harlow Group LLC, a health care law and consulting firm based near Boston, Massachusetts.noBusiness,Government & Organizations,Health,News & Politicshttps://healthblawg.com/2018/02/ed-marx-cio.htmlEd Marx, Cleveland Clinic CIO – Harlow on Healthcarehttp://feeds.healthblawg.com/~/523065148/0/healthblawg.html
http://feeds.healthblawg.com/~/523065148/0/healthblawg.html#respondMon, 05 Feb 2018 14:59:21 +0000https://healthblawg.com/?p=5476Harlow on Healthcare: Conversations with Healthcare Innovation Leaders

Ed Marx is the CIO of the Cleveland Clinic. He’s a Fellow of HIMSS and CHIME, and has been recognized by the two organizations as the CIO of the year. He partners with Clinic leaders, and his responsibilities include development and execution of strategic planning and governance, driving optimal resource utilization, team development and ensuring organizational support. He works to develop leaders and leverage digital healthcare technologies to enable superior business and clinical outcomes. You should check out his blog at HIStalk, calledCIO Unplugged, and you should follow him on Twitter: @marxtango.

My excuse for speaking with Ed was HIMSS’ recent recognition of the Cleveland Clinic with a Davies Award (read all about it at the link). Three projects — a heart failure checklist, cardiac codes reduction (the “VitalScout” project) and hypertension improvement — led to the Enterprise Davies Award. Beyond discussing what led to this recent accolade — for which Ed credits the team, also noting that most of the work was done before his arrival at Cleveland Clinic — it is always interesting to hear what he has to say about health IT.

Listen live at 8:30 am, 4:30 PM or 12:30 AM ET, Monday through Friday for the next two weeks at HealthcareNOW Radio. After that, you can listen on demand (See podcast information below.) Join the conversation on Twitter at #HarlowOnHC.

We kicked off our chat with Ed noting that while in the digital age we can be engaged in rapid innovation and improvement, there is no particular endpoint. Nirvana is always around the corner. There’s always another summit. He reminds us that we need to keep our work in perspective: Our children and grandchildren will look back at it and think it’s pretty primitive.

Ed’s take on the Cleveland Clinic and recognition like the Davies Award is that the institutional leadership and culture value passion, value the health IT folks working closely with front line clinical staff, value “failing forward,” as long as the failures don’t involve patient care. These values liberate thinking and allow teams to succeed.

This perspective reinforces a key theme of healthcare innovation and health IT improvement: the technical problems are often easier to solve than the cultural and political problems. Ed is focused on creating an environment in which passionate professionals can do good. He noted the VitalScout project was initiated by an employee who was passionate about an issue, saw an opportunity, brought it to the attention of leadership — and it is now saving lives, with a significant reduction in cardiac codes.

Ed brings his athlete’s mindset to work with him as well. As a duathlete on TeamUSA he’s been seeing another side of the power of data analytics. His cycling coach used a plethora of measurements and predictive analytics to adjust his training and got him to make a real mindshift: not focusing on speed (MPH) — the output — but instead on the stats that together yield the speed: cadence, wattage, heart rate. It’s all about focusing on the building blocks, rather than the ultimate goal, in order to better be able to do the work to reach that goal.

The IT organization exists to serve the clinical organization, and aside from making sure the trains run on time, a whole variety of interesting initiatives draw the IT teams in. One recent example is the Clinic’s collaboration with Oscar (the health insurance company). Oscar and the Clinic collaborated and created an interoperability solution that yielded better analytics leading to improved ability of clinicians to manage patients and improved patient engagement. (Part of what allows Ed and his team to help by being responsive is embedding IT business partners within the clinical institutes.)

We talked about shortening the “bench to bedside” time. I noted that the old saw would have that it takes 17 years to make that journey. Ed highlighted one Clinic example where this was reduced to two or three years, and another where a physician was able to leverage technology to address a problem and apply a solution within about a year.

In order to bring focus to the IT work across the institution, Ed and his team have three key priorities: Align, Optimize & Transform.

First: The goal is to align IT and clinical teams on the front end.

Second: Optimize means: improve governance, and achieve high reliability. Ed wants his team to be good stewards, to increase value by lowering cost and increase service.

Third: The IT function and infrastructure is transforming from legacy IT to a digital platform. The key questions include: Do you have a robust enough network to enable all the things that everyone wants to do? Ed notes the need to provide the infrastructure for IoT, mobile devices and secure caregiver communications. Everything doesn’t need to be on the same platform but everything needs to interoperate, communicate, share data.

Guiding progress on these, Ed articulated three “uber” priorities: security, deep analytics and using an agile approach. Ed is completely restructuring IT at Cleveland Clinic (beyond development and project management) based on agile principles. As he put it, it is “changing completely the way in which we work to be more effective, to become more efficient, to bring back some joy in work.”

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http://feeds.healthblawg.com/~/523065148/0/healthblawg.html/feed0Interview,Audio,Digital Health,Harlow on Healthcare,Healthcare Innovation,HIT,Health care policy,Health Law,PodcastEd Marx is the CIO of the Cleveland Clinic. He's a Fellow of HIMSS and CHIME, and has been recognized by the two organizations as the CIO of the year. He partners with Clinic leaders, and his responsibilities include development and execution of strategic planning and governance, driving optimal resource utilization, team development and ensuring organizational support. He works to develop leaders and leverage digital healthcare technologies to enable superior business and clinical outcomes. You should check out his blog at HIStalk, called CIO Unplugged, and you should follow him on Twitter: @marxtango.
My excuse for speaking with Ed was HIMSS' recent recognition of the Cleveland Clinic with a Davies Award (read all about it at the link). Three projects — a heart failure checklist, cardiac codes reduction (the “VitalScout” project) and hypertension improvement — led to the Enterprise Davies Award. Beyond discussing what led to this recent accolade — for which Ed credits the team, also noting that most of the work was done before his arrival at Cleveland Clinic — it is always interesting to hear what he has to say about health IT. ________________________________________________________
Listen live at 8:30 am, 4:30 PM or 12:30 AM ET, Monday through Friday for the next two weeks at HealthcareNOW Radio. After that, you can listen on demand (See podcast information below.) Join the conversation on Twitter at #HarlowOnHC. ________________________________________________________
We kicked off our chat with Ed noting that while in the digital age we can be engaged in rapid innovation and improvement, there is no particular endpoint. Nirvana is always around the corner. There's always another summit. He reminds us that we need to keep our work in perspective: Our children and grandchildren will look back at it and think it's pretty primitive.
Ed's take on the Cleveland Clinic and recognition like the Davies Award is that the institutional leadership and culture value passion, value the health IT folks working closely with front line clinical staff, value “failing forward,” as long as the failures don't involve patient care. These values liberate thinking and allow teams to succeed.
This perspective reinforces a key theme of healthcare innovation and health IT improvement: the technical problems are often easier to solve than the cultural and political problems. Ed is focused on creating an environment in which passionate professionals can do good. He noted the VitalScout project was initiated by an employee who was passionate about an issue, saw an opportunity, brought it to the attention of leadership — and it is now saving lives, with a significant reduction in cardiac codes.
Ed brings his athlete's mindset to work with him as well. As a duathlete on TeamUSA he's been seeing another side of the power of data analytics. His cycling coach used a plethora of measurements and predictive analytics to adjust his training and got him to make a real mindshift: not focusing on speed (MPH) — the output — but instead on the stats that together yield the speed: cadence, wattage, heart rate. It's all about focusing on the building blocks, rather than the ultimate goal, in order to better be able to do the work to reach that goal.
The IT organization exists to serve the clinical organization, and aside from making sure the trains run on time, a whole variety of interesting initiatives draw the IT teams in. One recent example is the Clinic's collaboration with Oscar (the health insurance company). Oscar and the Clinic collaborated and created an interoperability solution that yielded better analytics leading to improved ability of clinicians to manage patients and improved patient engagement. (Part of what allows Ed and his team to help by being responsive is embedding IT business partners within the clinical institutes.) ... Ed Marx is the CIO of the Cleveland Clinic. He's a Fellow of HIMSS and CHIME, and has been recognized by the two organizations as the CIO of the year. He partners with Clinic leaders, and his responsibilities include development and execution of ... David Harlowhttps://healthblawg.com/2018/01/titans-hoping-healthcare.htmlA tale of two tech titans hoping to help healthcarehttp://feeds.healthblawg.com/~/521474534/0/healthblawg.html
http://feeds.healthblawg.com/~/521474534/0/healthblawg.html#respondWed, 31 Jan 2018 00:43:25 +0000https://healthblawg.com/?p=5455Can the pent-up urgent need for change be addressed by a handful of big businesses?

We are awash in data. But we can’t access data when and where we need it.

We are awash in dollars. But untold billions are lost to waste, fraud and abuse.

Apple recently announced its foray into the personal health record market. Its initial offering is limited to a handful of health care systems, and the data collected and placed in the palms of our hands is PHR data, not full EHR data, as some outlets had reported, but the rollout has certainly engaged the commentariat in a deep dive into the pros and cons of Apple’s latest move in the healthcare sphere.

Amazon, together with Berkshire Hathaway and JP Morgan Chase, just announced the establishment of a new joint venture said to focus on technological solutions to lower healthcare costs for their employees. (They have, collectively, a lot of employees — over a million of them — and healthcare insurance company and other healthcare sector stocks dropped measurably following the announcement.) Presumably, this offering (whatever it is) will be made available to other employers in the future.

How do these announcements relate to each other and to other developments in the healthcare arena?

Apple’s PHR announcement is interesting despite the strikes against it. Let’s get some of those out of the way up front:

The data is limited to PHR data (and there are plenty of apps and services that can show you your PHR data on your phone already, though maybe they can’t integrate data from multiple providers as seamlessly — but see point 3, below)

iPhone users only amount to 15% of the smartphone market as a whole (though physicians are better represented among iPhone users — market share among physicians is at least 75% — so why is Apple focusing on patients rather than physicians?)

The pilot institutions are small in number and not likely to have many patients in common (thus limiting the demonstration of one of the key selling points of the offering: integrating data from multiple provider organizations)

Data flow is unidirectional (provider to patient only)

Some of these are short-term problems, though the truth is, we just don’t know whether Apple will be able to make the tool it’s rolling out ubiquitous. The road to hell is paved with good intentions, and the road to our digital health utopia of seamless data interoperability and transparency is littered with rusted hulks of other really great ideas.

The longer-term promise inherent in Apple’s announcement is that more people will be able to access more of their own health data more easily. If the pilot works out nicely, Apple will have other health care systems lining up to take part, and will eventually make it easy for health care providers of all shapes and sizes to hook up their EHR to the data pipes. Having the provenance of the data baked into the system will likely allow other health care providers to relax a little about getting information from patients — via their iPhones. (Imagine a telemedicine encounter via iPhone where the remote clinician can get a better picture of the patient’s health by being granted permission to access data in the Apple PHR on the phone. Imagine a diagnostic test where the results can be interpreted more accurately by accessing data in the Apple PHR.) Many consumer advocates prefer Apple’s approach to end user data (it stays on the phone and Apple doesn’t want to mine it) over the approaches taken by certain other tech titans (their services are free, which means you are the product). If this thing has legs, then expect a similar initiative on the Android side of the house (though it would likely not come with the Apple hands-off approach to personal data).

The Amazon-JP Morgan-Berkshire Hathaway effort may well be one expression of the future vision described by Dave Chase, for one. Dave is talking about change on a generational time scale to rationalize health benefits purchasing. (Check out his book and my recent chat with him.) The announcement of the titans may speed up the process.

The effort will never get off the ground without aggregating employee health data, and the sort of data standards and plumbing that enables the Apple project can also enable the Amazon project. These didn’t really exist in the days of Google Health, but the Argonaut Project and other initiatives have laid the table. (Perhaps Amazon etc. will key into the Apple PHR ecosystem, with patient consent, or perhaps they will build their own standards-based infrastructure — or perhaps both.) There have certainly been all sorts of employer-focused efforts to slay the healthcare beast before (workplace clinics, employer-sponsored health data networks, and more — valiant efforts, but not successful to date in moving us closer to the quadruple aim), and there are a whole variety of value-based care efforts that have been underway for years (and years) in the government payor and in the commercial payor universes, though they are either self-limiting, or haven’t quite ever gotten to the point of being really successful. There are many reasons why the PHR effort taken on by Apple and the employee health cost control effort by Amazon et al., which made sense before now but failed to reach escape velocity, might succeed at this point in time. One of the bright points that may give hope that the employee effort could succeed is, frankly, the proponents’ track record of success. Of particular interest is the Amazon experience in managing cost of products and the supply chain (which can translate nicely to pharmaceuticals and medical supplies) — not to mention its analytics superpowers (which could be retrained, though not overnight, from retail to healthcare), JP Morgan Chase’s experience in managing financial transactions and secure consumer access to confidential data (consumer banking seems to be at least ten years ahead of healthcare in terms of consumer-friendliness and interoperability), and Berkshire Hathaway’s experience in — well, in being Berkshire Hathaway. Ultimately, success in this effort is as much about controlling unit prices as it is about anything else. The real question is whether one million employees plus a couple million more family members, spread out across the country, equal sufficient critical mass to actually move the needle on unit prices.

The self-insured behemoth employers are doing well to initiate this project through a separate entity, and they will continue to do well if their employees can be confident that health information well beyond what is traditionally held by self-insured employee health plans will maintained in confidence, for the benefit of employee health and for no other reason. Questions about data privacy, and health data being used for employment-related decisions, would quickly torpedo this effort.

The internet is full of lists and examinations of potential future directions of the Apple PHR project and of the Amazon et al. employee health management project, and the ways in which they affect or are affected by other developments and combinations across the healthcare landscape. I won’t add to that carbon footprint today. (We’ll all think of more ways this could play out tomorrow — feel free to share your thoughts in the comments section.) Clearly, though, we have come to this pass because of intransigence of a number of entrenched interests (the “Mexican standoff” among health systems that don’t want to permit the liquidity of health data because they fear losing market share; the self-preservation instincts of sectors of the healthcare economy that stand to see the ground fall out from under their feet — one person’s waste is another person’s revenue, after all); in other words, we have a business and a political problem, not a technological problem, and it has now grown to gargantuan proportions.

Nevertheless, when the 800-pound gorillas in the business world decide to forge ahead despite the business challenges and clear a path forward, the technical solutions are more likely to be able to get a little sun and maybe even thrive.

]]>
http://feeds.healthblawg.com/~/521474534/0/healthblawg.html/feed0PHR,Digital Health,Healthcare Innovation,Health Reform,HIT,Health care policy,Health Law,mHealth,Health Insurance,Mobile health,Privacy,SecurityIt was the best of times. It was the worst of times.
We are awash in data. But we can't access data when and where we need it.
We are awash in dollars. But untold billions are lost to waste, fraud and abuse.
Apple recently announced its foray into the personal health record market. Its initial offering is limited to a handful of health care systems, and the data collected and placed in the palms of our hands is PHR data, not full EHR data, as some outlets had reported, but the rollout has certainly engaged the commentariat in a deep dive into the pros and cons of Apple's latest move in the healthcare sphere.
Amazon, together with Berkshire Hathaway and JP Morgan Chase, just announced the establishment of a new joint venture said to focus on technological solutions to lower healthcare costs for their employees. (They have, collectively, a lot of employees — over a million of them — and healthcare insurance company and other healthcare sector stocks dropped measurably following the announcement.) Presumably, this offering (whatever it is) will be made available to other employers in the future.
How do these announcements relate to each other and to other developments in the healthcare arena?
Apple's PHR announcement is interesting despite the strikes against it. Let's get some of those out of the way up front:
- The data is limited to PHR data (and there are plenty of apps and services that can show you your PHR data on your phone already, though maybe they can't integrate data from multiple providers as seamlessly — but see point 3, below) - iPhone users only amount to 15% of the smartphone market as a whole (though physicians are better represented among iPhone users — market share among physicians is at least 75% — so why is Apple focusing on patients rather than physicians?) - The pilot institutions are small in number and not likely to have many patients in common (thus limiting the demonstration of one of the key selling points of the offering: integrating data from multiple provider organizations) - Data flow is unidirectional (provider to patient only)
Some of these are short-term problems, though the truth is, we just don't know whether Apple will be able to make the tool it's rolling out ubiquitous. The road to hell is paved with good intentions, and the road to our digital health utopia of seamless data interoperability and transparency is littered with rusted hulks of other really great ideas.
The longer-term promise inherent in Apple's announcement is that more people will be able to access more of their own health data more easily. If the pilot works out nicely, Apple will have other health care systems lining up to take part, and will eventually make it easy for health care providers of all shapes and sizes to hook up their EHR to the data pipes. Having the provenance of the data baked into the system will likely allow other health care providers to relax a little about getting information from patients — via their iPhones. (Imagine a telemedicine encounter via iPhone where the remote clinician can get a better picture of the patient's health by being granted permission to access data in the Apple PHR on the phone. Imagine a diagnostic test where the results can be interpreted more accurately by accessing data in the Apple PHR.) Many consumer advocates prefer Apple's approach to end user data (it stays on the phone and Apple doesn't want to mine it) over the approaches taken by certain other tech titans (their services are free, which means you are the product). If this thing has legs, then expect a similar initiative on the Android side of the house (though it would likely not come with the Apple hands-off approach to personal data).
The Amazon-JP Morgan-Berkshire Hathaway effort may well be one expression of the future vision described by Dave Chase, for one. Dave is talking about change on a generational time scale to rationalize health ... It was the best of times. It was the worst of times.
We are awash in data. But we can't access data when and where we need it.
We are awash in dollars. But untold billions are lost to waste, fraud and abuse.
Apple recently announced its foray ... David Harlowhttps://healthblawg.com/2018/01/shrestha-healthcare-innovation.htmlRasu Shrestha, UPMC and Healthcare Innovation – Harlow On Healthcarehttp://feeds.healthblawg.com/~/519256260/0/healthblawg.html
http://feeds.healthblawg.com/~/519256260/0/healthblawg.html#respondMon, 22 Jan 2018 13:15:27 +0000https://healthblawg.com/?p=5437Harlow on Healthcare: Conversations with Healthcare Innovation Leaders

Rasu Shrestha is the Chief Innovation Officer of the University of Pittsburgh Medical Center and also serves as an Executive Vice President of UPMC Enterprises. You should follow him on Twitter: @RasuShrestha. We spoke about the meaning of innovation and about some of the innovations — past, present and future — at UPMC.

Rasu describes his north star as the best interests of the person — the consumer, the health plan member, the patient — and he sees that as being distinct from the notion of being patient-centered. Innovation, for UPMC, boils down to doing whatever is in the best interest of the person, deploying resources and building institutional culture to serve the best interests of the person.

UPMC has long been out in front in the realm of clinical innovation (consider the Starzl Institute, and its namesake’s pioneering work in liver transplantation), and it is now also focused on combining clinical excellence with analytical excellence. Rasu chose as one example a company spun out of UPMC, in a partnership with the Advisory Board: Evolent Health. The tools at the core of the company were developed by the UPMC health plan to better manage risk and, as Rasu says, the hunch that there was a market for these tools, packaged with advisory services, turned out to be correct; at the time of its IPO a couple of years a go, the company was valued at over $1 billion. Other examples: Curavi Health – telemedicine for long term care and other postacute care settings, and Lantern Health – making behavioral health tools more readily available that can reduce stigma and improve access to expertise.

More broadly, we spoke about the need to move from a focus on data and to a focus on information, and knowledge, enabling communication with patients or members through a variety of channels, to enable behavior change. As Rasu said, even though UPMC is building three new hospitals, there will be no net increase in the number of inpatient beds. Keeping people out of the hospital, nudging them towards healthier behaviors, will ultimately be better than providing more inpatient care at hospitals. The challenge is to operate a hospital where “heads and beds” are not the key metric of success. The goal is to manage illness and sustain patients in “the circle of wellness.”

Rasu’s vision of the future has technology becoming invisible. Artificial intelligence, machine learning, interoperability, all need to be harnessed more effectively to augment who we are as human beings, to eliminate the impediments to care that technology currently represent (e.g., 40% of physician-patient encounter spent with physician’s back to the patient while focused on the EHR screen). We need to leverage technology to give us better insights while also letting technology do the mundane work of integrating multiple data streams that need to be reviewed and analyzed.

Technology can help enable communication, connection, collaboration, empathy — we need to use technology in the best interests of the patient.

]]>
http://feeds.healthblawg.com/~/519256260/0/healthblawg.html/feed0Hospitals,Interview,Audio,Digital Health,Harlow on Healthcare,Healthcare Innovation,Artificial Intelligence,HIT,Health care policy,Health Law,PodcastRasu Shrestha is the Chief Innovation Officer of the University of Pittsburgh Medical Center and also serves as an Executive Vice President of UPMC Enterprises. You should follow him on Twitter: @RasuShrestha. We spoke about the meaning of innovation and about some of the innovations — past, present and future — at UPMC.
Rasu describes his north star as the best interests of the person — the consumer, the health plan member, the patient — and he sees that as being distinct from the notion of being patient-centered. Innovation, for UPMC, boils down to doing whatever is in the best interest of the person, deploying resources and building institutional culture to serve the best interests of the person.
UPMC has long been out in front in the realm of clinical innovation (consider the Starzl Institute, and its namesake's pioneering work in liver transplantation), and it is now also focused on combining clinical excellence with analytical excellence. Rasu chose as one example a company spun out of UPMC, in a partnership with the Advisory Board: Evolent Health. The tools at the core of the company were developed by the UPMC health plan to better manage risk and, as Rasu says, the hunch that there was a market for these tools, packaged with advisory services, turned out to be correct; at the time of its IPO a couple of years a go, the company was valued at over $1 billion. Other examples: Curavi Health – telemedicine for long term care and other postacute care settings, and Lantern Health – making behavioral health tools more readily available that can reduce stigma and improve access to expertise.
More broadly, we spoke about the need to move from a focus on data and to a focus on information, and knowledge, enabling communication with patients or members through a variety of channels, to enable behavior change. As Rasu said, even though UPMC is building three new hospitals, there will be no net increase in the number of inpatient beds. Keeping people out of the hospital, nudging them towards healthier behaviors, will ultimately be better than providing more inpatient care at hospitals. The challenge is to operate a hospital where “heads and beds” are not the key metric of success. The goal is to manage illness and sustain patients in “the circle of wellness.”
Rasu's vision of the future has technology becoming invisible. Artificial intelligence, machine learning, interoperability, all need to be harnessed more effectively to augment who we are as human beings, to eliminate the impediments to care that technology currently represent (e.g., 40% of physician-patient encounter spent with physician's back to the patient while focused on the EHR screen). We need to leverage technology to give us better insights while also letting technology do the mundane work of integrating multiple data streams that need to be reviewed and analyzed.
Technology can help enable communication, connection, collaboration, empathy — we need to use technology in the best interests of the patient.
I spoke with Rasu as part of my ongoing series of fireside chats with healthcare innovation leaders – Harlow on Healthcare, on HealthcareNOW Radio. You can catch me live weekdays at 8:30 am, 4:30 pm and 12:30 am ET. As each new show goes live, the last one joins the archive, available via SoundCloud or your favorite podcast app (iTunes, Stitcher, iHeartRadio). Your comments are welcome here. Join the conversation on Twitter at #HarlowOnHC.
David Harlow
The Harlow Group LLC
Health Care Law and Consulting Rasu Shrestha is the Chief Innovation Officer of the University of Pittsburgh Medical Center and also serves as an Executive Vice President of UPMC Enterprises. You should follow him on Twitter: @RasuShrestha. We spoke about the meaning of ... David Harlowhttps://healthblawg.com/2018/01/sms-phi-cms.htmlTexting patient information – The latest from CMShttp://feeds.healthblawg.com/~/516133122/0/healthblawg.html
http://feeds.healthblawg.com/~/516133122/0/healthblawg.html#commentsTue, 09 Jan 2018 15:08:38 +0000https://healthblawg.com/?p=5414Don't text orders, and be real careful about everything else.

Fear not, gentle reader. We are now back to the status quo ante, at least with respect to the question of whether and how texting may be used in hospitals subject to the Medicare Conditions of Participation (i.e., most hospitals). CMS’s Survey and Certification Group published a memo sent to all state survey agency directors at the end of December regarding Texting of Patient Information among Healthcare Providers.

The problems with unencrypted texting are threefold from the CoP perspective:

Medical records (accurate, properly maintained, accessible, authenticated, secure) must be retained for five years

Patient records must be kept confidential

Orders are to be entered into a medical record by hand or via CPOE (CPOE, unlike texting, is permitted because it is set up to auto-download into the EHR, with date, time and authentication taken care of)

The CMS summation:

CMS recognizes that the use of texting as a means of communication with other members of the healthcare team has become an essential and valuable means of communication among the team members. In order to be compliant with the CoPs or CfCs [Conditions for Coverage], all providers must utilize and maintain systems/platforms that are secure, encrypted, and minimize the risks to patient privacy and confidentiality as per HIPAA regulations and the CoPs or CfCs. It is expected that providers/organizations will implement procedures/processes that routinely assess the security and integrity of the texting systems/platforms that are being utilized, in order to avoid negative outcomes that could compromise the care of patients.

Bottom line: Communication among team members via text message could be OK (as long as it’s secure), but orders must be communicated via CPOE.

So, when you’re shopping for your next CPOE tool, remember this: Any smartphone-based tool for CPOE must meet the CMS requirements outlined above as well as all HIPAA requirements.

This is clear . . . until the next clarification comes along. Other provider types are left to reason by analogy.

]]>
http://feeds.healthblawg.com/~/516133122/0/healthblawg.html/feed1Physicians,Hospitals,Compliance,Digital Health,CMS,HIT,Medicare,Health care policy,Health Law,HHS,Privacy,Security,HIPAACMS has a communications problem. Together with the Joint Commission, CMS issued joint guidance on the use of SMS messaging for clinical communications just over a year ago. Last month, the Health Care Compliance Association published a story stating that CMS had sent emails to two different hospitals stating that text messaging (including secure messaging services) is verboten. The apoplectic response of the regulated community and commentariat to the off-message message conveyed via email moved CMS to issue an official statement more in line with the joint communiqué of December 2016.
Fear not, gentle reader. We are now back to the status quo ante, at least with respect to the question of whether and how texting may be used in hospitals subject to the Medicare Conditions of Participation (i.e., most hospitals). CMS's Survey and Certification Group published a memo sent to all state survey agency directors at the end of December regarding Texting of Patient Information among Healthcare Providers.
The problems with unencrypted texting are threefold from the CoP perspective:
- Medical records (accurate, properly maintained, accessible, authenticated, secure) must be retained for five years - Patient records must be kept confidential - Orders are to be entered into a medical record by hand or via CPOE (CPOE, unlike texting, is permitted because it is set up to auto-download into the EHR, with date, time and authentication taken care of)
The CMS summation:
CMS recognizes that the use of texting as a means of communication with other members of the healthcare team has become an essential and valuable means of communication among the team members. In order to be compliant with the CoPs or CfCs [Conditions for Coverage], all providers must utilize and maintain systems/platforms that are secure, encrypted, and minimize the risks to patient privacy and confidentiality as per HIPAA regulations and the CoPs or CfCs. It is expected that providers/organizations will implement procedures/processes that routinely assess the security and integrity of the texting systems/platforms that are being utilized, in order to avoid negative outcomes that could compromise the care of patients.
Bottom line: Communication among team members via text message could be OK (as long as it's secure), but orders must be communicated via CPOE.
So, when you're shopping for your next CPOE tool, remember this: Any smartphone-based tool for CPOE must meet the CMS requirements outlined above as well as all HIPAA requirements.
This is clear . . . until the next clarification comes along. Other provider types are left to reason by analogy.
David Harlow
The Harlow Group LLC
Health Care Law and Consulting CMS has a communications problem. Together with the Joint Commission, CMS issued joint guidance on the use of SMS messaging for clinical communications just over a year ago. Last month, the Health Care Compliance Association published a story ... David Harlowhttps://healthblawg.com/2018/01/cindy-friend-caradigm.htmlCindy Friend, Caradigm and Population Health – Harlow on Healthcarehttp://feeds.healthblawg.com/~/515863002/0/healthblawg.html
http://feeds.healthblawg.com/~/515863002/0/healthblawg.html#commentsMon, 08 Jan 2018 13:05:08 +0000https://healthblawg.com/?p=5408Harlow on Healthcare: Conversations with Healthcare Innovation Leaders

I spoke recently with Cindy Friend, who is Vice President of Clinical Population Health Solutions & Transformation at Caradigm – a GE Healthcare company Twitter: @caradigm. Cindy is a registered nurse with more than 20 years combined experience in healthcare administration, clinical delivery, and health information technology both in the public and private sectors. Our conversation focused on the opportunities for improving population health through ACOs.

Caradigm is focusing on population health by stratifying patients with multiple chronic conditions, and supporting ACOs in managing their care. The key is looking at entire communities in order to prioritize efforts at the populations level. For example, nationally we may have a heightened focus on heart failure and diabetes; however, Cindy noted that in a mid-Atlantic market she was working with, the key chronic condition to focus on was, surprisingly, osteoarthritis.

Behavioral health, said Cindy, doesn’t necessarily have to be integrated into the delivery system, but assessments should be integrated (e.g., PHQ-9’s may be administered by primary care providers), so that the behavioral health data may be integrated into the analytics framework used to manage population health. Other sorts of information that need to be captured and integrated include what we call social determinants of health, including for example literacy levels of patients — a critical but often overlooked issue.

Cindy is more optimistic than I am about the successes of ACOs; she discussed some recent reports on ACOs and noted that we’re still in the early days of this care delivery and payment innovation. You can see a bit of my perspective on the relatively small savings realized to date here. We also discussed some of the bright spots in the ACO landscape, and the benefits to be gleaned from looking closely at care management across the continuum of care, and from improving provider engagement as well as patient and caregiver engagement, using systems supporting improved data collection and information sharing, which can lead to better integration across the continuum of care.

When I asked Cindy what she would like to see five years from now, she said she would love to see “literally, not another paper record . . . not another post-it note around.”

]]>
http://feeds.healthblawg.com/~/515863002/0/healthblawg.html/feed1Interview,Population Health,Audio,Harlow on Healthcare,Accountable Care Organization,Health Reform,HIT,Health care policy,Health Law,Chronic care,Value Based Purchasing,Pay for performance,Podcast,Social Determinants of HealthI spoke recently with Cindy Friend, who is Vice President of Clinical Population Health Solutions & Transformation at Caradigm – a GE Healthcare company Twitter: @caradigm. Cindy is a registered nurse with more than 20 years combined experience in healthcare administration, clinical delivery, and health information technology both in the public and private sectors. Our conversation focused on the opportunities for improving population health through ACOs.
Caradigm is focusing on population health by stratifying patients with multiple chronic conditions, and supporting ACOs in managing their care. The key is looking at entire communities in order to prioritize efforts at the populations level. For example, nationally we may have a heightened focus on heart failure and diabetes; however, Cindy noted that in a mid-Atlantic market she was working with, the key chronic condition to focus on was, surprisingly, osteoarthritis.
Behavioral health, said Cindy, doesn't necessarily have to be integrated into the delivery system, but assessments should be integrated (e.g., PHQ-9's may be administered by primary care providers), so that the behavioral health data may be integrated into the analytics framework used to manage population health. Other sorts of information that need to be captured and integrated include what we call social determinants of health, including for example literacy levels of patients — a critical but often overlooked issue.
Cindy is more optimistic than I am about the successes of ACOs; she discussed some recent reports on ACOs and noted that we're still in the early days of this care delivery and payment innovation. You can see a bit of my perspective on the relatively small savings realized to date here. We also discussed some of the bright spots in the ACO landscape, and the benefits to be gleaned from looking closely at care management across the continuum of care, and from improving provider engagement as well as patient and caregiver engagement, using systems supporting improved data collection and information sharing, which can lead to better integration across the continuum of care.
When I asked Cindy what she would like to see five years from now, she said she would love to see “literally, not another paper record . . . not another post-it note around.”
I spoke with Cindy as part of my ongoing series of fireside chats with healthcare innovation leaders – Harlow on Healthcare, on HealthcareNOW Radio. You can catch me live weekdays at 8:30 am, 4:30 pm and 12:30 am ET. As each new show goes live, the last one joins the archive, available via SoundCloud or your favorite podcast app (iTunes, Stitcher, iHeartRadio). Your comments are welcome here. Join the conversation on Twitter at #HarlowOnHC.
David Harlow
The Harlow Group LLC
Health Care Law and Consulting I spoke recently with Cindy Friend, who is Vice President of Clinical Population Health Solutions & Transformation at Caradigm – a GE Healthcare company Twitter: @caradigm. Cindy is a registered nurse with more than 20 years combined ... David Harlowhttps://healthblawg.com/2017/12/fda-digital-health.htmlFDA and Digital Health Regulationhttp://feeds.healthblawg.com/~/513003248/0/healthblawg.html
http://feeds.healthblawg.com/~/513003248/0/healthblawg.html#commentsTue, 26 Dec 2017 14:59:05 +0000https://healthblawg.com/?p=5340Digital Health in a New Regulatory Era, or, When is a Digital Service a Device?

The FDA had a digital health banner day on December 7, announcing one final guidance and two draft guidance documents (with a 60-day comment period). Collectively, these guidances cover a range of digital health issues, and it is worth reading FDA Commissioner Scott Gottlieb’s statement about them as well as each individual document:

These publications come as part of the FDA’s effort to improve its approach to digital health, to continue to work on drawing the line between digital health tools that are properly regulated as “devices” by the FDA and those that are not. Since some digital health tools will inevitably be subject to regulation while many will not, the agency has previously issued a high-level plan for streamlining its processes. Issuing these guideline documents is a further step towards creating some predictability for folks in the industry who may shy away from including certain functionality in products for fear of being subject to unknown sorts of regulatory review by the FDA.

The agency has a history of articulating its position on where the line is to be drawn, on how it is to exercise its discretion in regulating devices. While many “consumer-grade” and “book-on-a-screen” sorts of tools will fall into the category of things the FDA doesn’t want to spend its time reviewing, it should come as no surprise that clinical decision support (“CDS”) software or software as a medical device (“SaMD”) will include digital tools including proprietary algorithms where the treating physician is unable to “look under the hood” and check the tool’s work, replicating the tool’s “thought process.” We also need to remember that these issuances come in the context of the broader agency approach to digital health, an ongoing struggle with how to regulate in this arena. How does an agency that can take months or years to review an application respond to an industry that iterates weekly or monthly with new versions of applications being released, or even more frequently, and more obscurely, as an artificial intelligence takes in new data and continually adjusts an algorithm that is an inscrutable “black box” as far as regulators and clinicians are concerned, yet is being put forward as a source of diagnostic or treatment recommendations?

FDA has done a very good job of moving the ball forward, though there is certainly room for improvement, and there is opportunity for comment on two of the three guidance documents announced. It is worth noting that the SaMD efforts are based on the principles articulated by a group of medical device regulators from around the world (IMDRF) which chartered a working group to look at SaMD; the IMDRF document was unanimously approved by its management committee and was adopted by the FDA.

The draft CDS and PDS Guidance is intended to clarify what sorts of digital health tools will not be considered devices and thus not regulated by the FDA. Examples of things that will still be considered medical devices include:

software programs that are intended to process or analyze medical images

signals from in vitro diagnostic devices

patterns acquired from a processor like an electrocardiogram that use analytical functionalities to make treatment recommendations

The draft Cures Act Guidance follows the legislative language calling on the agency to clarify that its jurisdiction does not extend to so-called lifestyle apps, so long as they are not designed for use in the diagnosis, cure, mitigation, treatment or prevention of a disease or condition. These could include “general wellness” apps addressing things like:

weight management

physical fitness

relaxation or stress management

mental acuity

self-esteem

sleep management

sexual function

Of course, one would hope that consumer protection regulators would step in to keep a lid on the quackery that is sometimes offered in those categories. While there are useful apps in each of those categories, there are plenty of “lifestyle” apps that are not particularly useful and could be harmful. A separate issue is the range of permissions granted to any of these apps by a user when accepting their terms of use and privacy policy. (Caveat emptor!)

The final SaMD Guidance builds upon three prior guidance documents, all of which are adopted by IMDRF. (If you’re being compliant or adherent you’ll read those three first: SaMD: Key Definitions (2013), SaMD: Possible Framework for Risk Categorization and Corresponding Considerations(2014), and SaMD: Application of Quality Management System (2015).) The IMDRF recognizes that the regulated community touched by this guidance is more software-focused than hardware-focused (and is not the traditional medical device regulated community), thus requiring some new approaches to data gathering and analysis. This guidance identifies the three-part analytical process that an SaMD producer must go through, with citations to other relevant IMDRF guidance documents: (i) valid clinical association, (ii)analytical validation and (iii) clinical validation. The guidance emphasizes the need to incorporate real world data into the evaluation process and and the need to use independent review — noting that the need for independent review increases as the risk categorization of the SaMD increases.

The issuance of these guidance documents is a positive step forward by the FDA, but the devil is in the details. Comments on the draft guidance documents and the process of finalizing them will create greater certainty for the regulated community. In parallel, FDA has rolled out a fast-track approach to regulating in the digital health. While some have questioned the pre-certification process as being beyond the legal scope of the FDA’s discretion, the agency has enrolled a handful of large companies in the FDA’s pre-certification program, and is focusing on developers and their processes, rather than on the digital health products themselves, in order to deal with some of the fundamental difficulties in regulating in this arena.

]]>
http://feeds.healthblawg.com/~/513003248/0/healthblawg.html/feed2Compliance,FDA,Medical Devices,Patient safety,Digital Health,Wellness,Healthcare Innovation,Precision Medicine,Artificial Intelligence,Machine Learning,HIT,Health care policy,Health Law,mHealth,Mobile health,Quantified SelfThe FDA had a digital health banner day on December 7, announcing one final guidance and two draft guidance documents (with a 60-day comment period). Collectively, these guidances cover a range of digital health issues, and it is worth reading FDA Commissioner Scott Gottlieb's statement about them as well as each individual document:
- Clinical and Patient Decision Support Software (CDS and PDS) (Draft) - Changes to Existing Medical Software Policies Resulting From Section 3060 of the 21st Century Cures Act (Cures Act) (Draft) - Software as a Medical Device: Clinical Evaluation (SaMD) (Final)
These publications come as part of the FDA's effort to improve its approach to digital health, to continue to work on drawing the line between digital health tools that are properly regulated as “devices” by the FDA and those that are not. Since some digital health tools will inevitably be subject to regulation while many will not, the agency has previously issued a high-level plan for streamlining its processes. Issuing these guideline documents is a further step towards creating some predictability for folks in the industry who may shy away from including certain functionality in products for fear of being subject to unknown sorts of regulatory review by the FDA.
The agency has a history of articulating its position on where the line is to be drawn, on how it is to exercise its discretion in regulating devices. While many “consumer-grade” and “book-on-a-screen” sorts of tools will fall into the category of things the FDA doesn't want to spend its time reviewing, it should come as no surprise that clinical decision support (“CDS”) software or software as a medical device (“SaMD”) will include digital tools including proprietary algorithms where the treating physician is unable to “look under the hood” and check the tool's work, replicating the tool's “thought process.” We also need to remember that these issuances come in the context of the broader agency approach to digital health, an ongoing struggle with how to regulate in this arena. How does an agency that can take months or years to review an application respond to an industry that iterates weekly or monthly with new versions of applications being released, or even more frequently, and more obscurely, as an artificial intelligence takes in new data and continually adjusts an algorithm that is an inscrutable “black box” as far as regulators and clinicians are concerned, yet is being put forward as a source of diagnostic or treatment recommendations?
FDA has done a very good job of moving the ball forward, though there is certainly room for improvement, and there is opportunity for comment on two of the three guidance documents announced. It is worth noting that the SaMD efforts are based on the principles articulated by a group of medical device regulators from around the world (IMDRF) which chartered a working group to look at SaMD; the IMDRF document was unanimously approved by its management committee and was adopted by the FDA.
The draft CDS and PDS Guidance is intended to clarify what sorts of digital health tools will not be considered devices and thus not regulated by the FDA. Examples of things that will still be considered medical devices include:
- software programs that are intended to process or analyze medical images - signals from in vitro diagnostic devices - patterns acquired from a processor like an electrocardiogram that use analytical functionalities to make treatment recommendations
The draft Cures Act Guidance follows the legislative language calling on the agency to clarify that its jurisdiction does not extend to so-called lifestyle apps, so long as they are not designed for use in the diagnosis, cure, mitigation, treatment or prevention of a disease or condition. These could include “general ... The FDA had a digital health banner day on December 7, announcing one final guidance and two draft guidance documents (with a 60-day comment period). Collectively, these guidances cover a range of digital health issues, and it is worth reading FDA ... David Harlowhttps://healthblawg.com/2017/12/lamberts-dpc-healthcare.htmlDr. Rob Lamberts, Direct Primary Care, and the Future of Healthcare – Harlow on Healthcarehttp://feeds.healthblawg.com/~/512817576/0/healthblawg.html
http://feeds.healthblawg.com/~/512817576/0/healthblawg.html#respondMon, 25 Dec 2017 15:00:46 +0000https://healthblawg.com/?p=5381Harlow on Healthcare: Conversations with Healthcare Innovation Leaders

I spoke recently with Dr. Rob Lamberts – @doc_rob on Twitter – about EHRs and direct primary care. I first met Doc Rob through our involvement in the late lamented Grand Rounds (the notable medical blog carnival – you can find some editions here). You should read his blog, Musings of a Distractible Mind, and perhaps you will be able to divine the origins or meaning of his deep interest in llamas.

Rob was an early adopter of electronic health records in his practice, after having been exposed to EHRs during his training. He became the president of the GE Centricity user group, and his group practice won a HIMSS Davies Award for its innovative and effective use of its EHR. He was an avid user and proponent of the EHR, seeing it as a valuable tool for improving the quality of patient care. When implementing the EHR in his practice, he focused on fitting the EHR to his practice, not vice versa. He became disillusioned with the “system” when the HITECH Act mandated meaningful use of certified EHRs and he saw computer-aided efficiencies supplanted by check-the-box operations that made his work less efficient and was unrelated to promoting good clinical care.

Five years ago, Rob left his group practice and founded a direct primary care practice, flipping the traditional practice model from a fee for service model where the practice needs to bring patients into the office in order to generate revenue to the DPC model where it is better for both doctor and patient to manage more care remotely — by phone or text, tuned to the patient’s preferences — and finances are not harmed because patients pay a monthly fee to the practice. In his experience, only about 25% of patients who had office appointments in the final years of his traditional fee for service practice really needed to come into the office; these days he has two to three times as many virtual visits as in-office visits.

The change in practice transformed recordkeeping for Rob’s practice, raising the question: What does a medical record look like if it used not for billing but only for patient care? He started with a homegrown tool but now uses one of the commercial tools available to the DPC community (Elation).

Rob was an early adopter of the DPC model, and in part he credits Dave Chase with motivating him to move his practice in this direction. (Check out the recent Harlow on Healthcare episode with Dave Chase.) Over the past five years, the universe of DPC practices in the US has expanded from under 100 to over 1000.

One drawback to being this far out in front is that Rob, sadly, still has to communicate with specialists via fax … though he says that some specialists will actually use the credentials he provides and log into his system so they can read online his detailed notes regarding the reason for the consult.

Rob believes that eventually artificial intelligence and machine learning will help him in his practice by ensuring the accuracy of patient records, identifying prescription drug interactions and potential side effects, access to longitudinal patient records including prescription medication histories, and eventually by recognizing patterns of how patients are doing before a patient calls so that the practice may be more proactive in managing the health of its patients. He laments the transformation of taking a patient history into filling out an EHR template, and sees AI as a potential tool for returning to taking a narrative history, asking the right questions, making the encounter more human again, and freeing clinicians for most of the time that they currently spend in front of the computer — it’s 50% of their working hours now, and could be brought down to 10%.

Eventually, the computer systems we use should be able to let the clinician know automatically how the patient is doing after the office visit (or virtual visit).

Leveraging the tools we have now, and the tools we should have in the future, will allow us to spend less on care, spend less on medications.

As Rob says, “Most of my patients do not want more care — they understand that and with a little education they can understand that much better.”

]]>
http://feeds.healthblawg.com/~/512817576/0/healthblawg.html/feed0Physicians,Interview,Harlow on Healthcare,Healthcare Innovation,Health Information Exchange,Artificial Intelligence,Health Reform,Machine Learning,HIT,Direct Primary Care,EHR,Health care policy,Health Law,Podcast
I spoke recently with Dr. Rob Lamberts – @doc_rob on Twitter – about EHRs and direct primary care. I first met Doc Rob through our involvement in the late lamented Grand Rounds (the notable medical blog carnival – you can find some editions here). You should read his blog, Musings of a Distractible Mind, and perhaps you will be able to divine the origins or meaning of his deep interest in llamas.
Rob was an early adopter of electronic health records in his practice, after having been exposed to EHRs during his training. He became the president of the GE Centricity user group, and his group practice won a HIMSS Davies Award for its innovative and effective use of its EHR. He was an avid user and proponent of the EHR, seeing it as a valuable tool for improving the quality of patient care. When implementing the EHR in his practice, he focused on fitting the EHR to his practice, not vice versa. He became disillusioned with the “system” when the HITECH Act mandated meaningful use of certified EHRs and he saw computer-aided efficiencies supplanted by check-the-box operations that made his work less efficient and was unrelated to promoting good clinical care.
Five years ago, Rob left his group practice and founded a direct primary care practice, flipping the traditional practice model from a fee for service model where the practice needs to bring patients into the office in order to generate revenue to the DPC model where it is better for both doctor and patient to manage more care remotely — by phone or text, tuned to the patient's preferences — and finances are not harmed because patients pay a monthly fee to the practice. In his experience, only about 25% of patients who had office appointments in the final years of his traditional fee for service practice really needed to come into the office; these days he has two to three times as many virtual visits as in-office visits.
The change in practice transformed recordkeeping for Rob's practice, raising the question: What does a medical record look like if it used not for billing but only for patient care? He started with a homegrown tool but now uses one of the commercial tools available to the DPC community (Elation).
Rob was an early adopter of the DPC model, and in part he credits Dave Chase with motivating him to move his practice in this direction. (Check out the recent Harlow on Healthcare episode with Dave Chase.) Over the past five years, the universe of DPC practices in the US has expanded from under 100 to over 1000.
One drawback to being this far out in front is that Rob, sadly, still has to communicate with specialists via fax … though he says that some specialists will actually use the credentials he provides and log into his system so they can read online his detailed notes regarding the reason for the consult.
Rob believes that eventually artificial intelligence and machine learning will help him in his practice by ensuring the accuracy of patient records, identifying prescription drug interactions and potential side effects, access to longitudinal patient records including prescription medication histories, and eventually by recognizing patterns of how patients are doing before a patient calls so that the practice may be more proactive in managing the health of its patients. He laments the transformation of taking a patient history into filling out an EHR template, and sees AI as a potential tool for returning to taking a narrative history, asking the right questions, making the encounter more human again, and freeing clinicians for most of the time that they currently spend in front of the computer — it's 50% of their working hours now, and could be brought down to 10%.
Eventually, the computer systems we use should be able to let the clinician know automatically how the patient is doing after the office visit (or virtual visit).
Leveraging the tools we have now, and the ... David Harlowhttps://healthblawg.com/2017/12/shelter-health-insurance.htmlFood, Shelter, Health Insurance – #SDOHhttp://feeds.healthblawg.com/~/511332900/0/healthblawg.html
http://feeds.healthblawg.com/~/511332900/0/healthblawg.html#respondMon, 18 Dec 2017 14:50:09 +0000https://healthblawg.com/?p=5351Sometimes the key determinants of health are not really health care services or resources

It is often said that social determinants of health are more important than many of the things we think of as more closely associated with health, such as health care services, health literacy, engagement in one’s own health care, adherence to prescribed health care treatment and medication.

In some of my recent podcast interviews, I’ve discussed population health with guests on Harlow on Healthcare. Not surprisingly, clinicians working for healthcare technology, health data or digital health companies have a perspective on population health that is closely aligned with the tools and services they provide.

Once in a while, health care provider organizations are able to pull back, take a broad perspective, and understand that addressing social determinants of health can be a win-win proposition. What do I mean by that? I mean that for short dollars a health care organization can go out of pocket, and provide goods and services to members of its community that provide an immediate benefit to those individuals and also tend to lower costs for the institution and for the system at large.

Exhibit B: Seeking to ensure that the 25% of patients served in a big city ED who are homeless get connected with housing options. Homelessness can cause and exacerbate medical issues which can be more costly to treat than they are to prevent. The prescription is housing.

Somehow, Congress has not gotten the message. Instead, the GOP has been hell-bent on eviscerating Obamacare indirectly (having failed to do so directly). Eliminating the individual mandate is projected to result in 10,000 preventable deaths per year.

Here’s hoping that someday government can find its way back to promoting population health.

]]>
http://feeds.healthblawg.com/~/511332900/0/healthblawg.html/feed0Health Reform,Health care policy,Health Law,Social Determinants of HealthIt is often said that social determinants of health are more important than many of the things we think of as more closely associated with health, such as health care services, health literacy, engagement in one's own health care, adherence to prescribed health care treatment and medication.
In some of my recent podcast interviews, I've discussed population health with guests on Harlow on Healthcare. Not surprisingly, clinicians working for healthcare technology, health data or digital health companies have a perspective on population health that is closely aligned with the tools and services they provide.
Once in a while, health care provider organizations are able to pull back, take a broad perspective, and understand that addressing social determinants of health can be a win-win proposition. What do I mean by that? I mean that for short dollars a health care organization can go out of pocket, and provide goods and services to members of its community that provide an immediate benefit to those individuals and also tend to lower costs for the institution and for the system at large.
Exhibit A: Serving meals to folks who otherwise present in the ED on weekends mostly because it's a guaranteed way to get a “free” meal. This gets the hospital out of the business of operating the most expensive soup kitchen imaginable.
Exhibit B: Seeking to ensure that the 25% of patients served in a big city ED who are homeless get connected with housing options. Homelessness can cause and exacerbate medical issues which can be more costly to treat than they are to prevent. The prescription is housing.
Somehow, Congress has not gotten the message. Instead, the GOP has been hell-bent on eviscerating Obamacare indirectly (having failed to do so directly). Eliminating the individual mandate is projected to result in 10,000 preventable deaths per year.
Here's hoping that someday government can find its way back to promoting population health.
David Harlow
The Harlow Group LLC
Health Care Law and Consulting
Image: Reed George via Flickr CC It is often said that social determinants of health are more important than many of the things we think of as more closely associated with health, such as health care services, health literacy, engagement in one's own health care, adherence to ... David Harlowhttps://healthblawg.com/2017/12/terheyden-invisible-healthcare.htmlDr. Nick van Terheyden and the Invisible Patient – Harlow On Healthcarehttp://feeds.healthblawg.com/~/509256950/0/healthblawg.html
http://feeds.healthblawg.com/~/509256950/0/healthblawg.html#commentsMon, 11 Dec 2017 14:16:07 +0000https://healthblawg.com/?p=5341Harlow on Healthcare: Conversations with Healthcare Innovation Leaders

As Chief Medical Officer at BaseHealth, Dr. Nick van Terheyden (aka “Dr. Nick“) serves as the voice of the physician at the company. He provides strategic insights in product development and marketing as BaseHealth works to bring to market a predictive, evidence-based and data-driven population health management platform.

Base Health is working from the ground up to build a new approach to population health, focusing on the individual patient, what Base Health calls “the invisible patient.” This is the individual we all know exists who is going to have a catastrophic interaction with the health care system but we don’t yet know who and what – this is the patient who presents in the emergency room with a significant clinical problem leading to costly treatments and significant long term health issues. As Dr. Nick says, “We find the patient before that takes place.”

I spoke with Nick about his new role at Base Health, and he is very excited. Dr. Nick says that the way we practice medicine today is riskier than it needs to be. He likens relying on claims data alone (as he posits many health systems currently do, in their efforts to manage patient health) to driving down the highway while looking in the rear view mirror. Instead he urges that we must Look at the EHR, at Rx data, appointment data, anything that exists about the patient, and assemble it in one place, and examine it carefully. Base Health combines more comprehensive information about individuals and analyzes it using its machine learning knowledgebase including all 150 million-plus medical papers in the PubMed database.

Using these tools, BaseHealth is able in 90% of cases to accurately “risk-adjust” a patient population, thereby enabling the clinical care system to focus its efforts on providing preventive services to those at greatest risk. The system has been implemented at Banner Health, for certain conditions, in the Medicare Advantage population, after Banner tested the BaseHealth algorithms by applying them to old data about patients that had been followed at Banner. BaseHealth predictions based on the old data closely tracked actual experience in the same cohort of patients.

By providing more accurate risk adjustment, Banner Health says it is able to provide a positive ROI for the payor and provider organizations, and benefits to the patients as well. If previously under-reported risk is reported accurately earlier, the Medicare Advantage plan and a risk-bearing provider organization would be paid a higher risk-adjusted capitation rate earlier in time, giving them a longer runway of greater resources to use to address the unmet needs of the invisible patient.

]]>
http://feeds.healthblawg.com/~/509256950/0/healthblawg.html/feed1Interview,Population Health,Harlow on Healthcare,Healthcare Innovation,Medicare,Health care policy,Health Law,PodcastAs Chief Medical Officer at BaseHealth, Dr. Nick van Terheyden (aka “Dr. Nick“) serves as the voice of the physician at the company. He provides strategic insights in product development and marketing as BaseHealth works to bring to market a predictive, evidence-based and data-driven population health management platform.
Base Health is working from the ground up to build a new approach to population health, focusing on the individual patient, what Base Health calls “the invisible patient.” This is the individual we all know exists who is going to have a catastrophic interaction with the health care system but we don’t yet know who and what – this is the patient who presents in the emergency room with a significant clinical problem leading to costly treatments and significant long term health issues. As Dr. Nick says, “We find the patient before that takes place.”
I spoke with Nick about his new role at Base Health, and he is very excited. Dr. Nick says that the way we practice medicine today is riskier than it needs to be. He likens relying on claims data alone (as he posits many health systems currently do, in their efforts to manage patient health) to driving down the highway while looking in the rear view mirror. Instead he urges that we must Look at the EHR, at Rx data, appointment data, anything that exists about the patient, and assemble it in one place, and examine it carefully. Base Health combines more comprehensive information about individuals and analyzes it using its machine learning knowledgebase including all 150 million-plus medical papers in the PubMed database.
Using these tools, BaseHealth is able in 90% of cases to accurately “risk-adjust” a patient population, thereby enabling the clinical care system to focus its efforts on providing preventive services to those at greatest risk. The system has been implemented at Banner Health, for certain conditions, in the Medicare Advantage population, after Banner tested the BaseHealth algorithms by applying them to old data about patients that had been followed at Banner. BaseHealth predictions based on the old data closely tracked actual experience in the same cohort of patients.
By providing more accurate risk adjustment, Banner Health says it is able to provide a positive ROI for the payor and provider organizations, and benefits to the patients as well. If previously under-reported risk is reported accurately earlier, the Medicare Advantage plan and a risk-bearing provider organization would be paid a higher risk-adjusted capitation rate earlier in time, giving them a longer runway of greater resources to use to address the unmet needs of the invisible patient.
Please have a listen to learn more.
I spoke with Nick as part of my ongoing series of fireside chats with healthcare innovation leaders – Harlow on Healthcare, on HealthcareNOW Radio. You can catch me live weekdays at 8:30 am, 4:30 pm and 12:30 am ET. As each new show goes live, the last one joins the archive, available via SoundCloud or your favorite podcast app (iTunes, Stitcher). Your comments are welcome here. Join the conversation on Twitter at #HarlowOnHC.
David Harlow
The Harlow Group LLC
Health Care Law and Consulting As Chief Medical Officer at BaseHealth, Dr. Nick van Terheyden (aka “Dr. Nick“) serves as the voice of the physician at the company. He provides strategic insights in product development and marketing as BaseHealth works to bring to ... David Harlowhttps://healthblawg.com/2017/11/chase-benefits-rosetta.htmlDave Chase and the Long March on Health Care Benefits – Harlow on Healthcarehttp://feeds.healthblawg.com/~/500272584/0/healthblawg.html
http://feeds.healthblawg.com/~/500272584/0/healthblawg.html#respondMon, 27 Nov 2017 14:00:21 +0000https://healthblawg.com/?p=5312Harlow on Healthcare: Conversations with Healthcare Innovation Leaders

Dave Chase, co-founder of the Health Rosetta Institute, is seeking to identify and scale successes in health care that deliver on the Quadruple Aim. He is focused on the current state of the healthcare industry as an “extractive” industry, and the need to change it by changing health care benefits and services purchasing behavior among the country’s employers. As he puts it, we didn’t get better lighting by optimizing oil lamps.

The current evolution of Dave’s thinking is captured in his recent book, CEO’s Guide to Restoring the American Dream: How to Deliver World Class Health Care to Your Employees at Half the Cost (available via the Health Rosetta Institute website). In his view, we need to rationalize health benefits purchasing in order to stop the unceasing increases in spending with no increase in quality or value. There is a profound disconnect between price and value, and there is significant overtreatment of individuals. On the pricing front, many employer-based health plans seem content to pay just about whatever the providers charge, while better-managed plans focus on reference-based pricing (say, 140% of Medicare fee schedule). Some would say that, as individual employees have more and more responsibility for health care costs, the self-insured employer health plans’ failure to better manage health care spending is a massive breach of fiduciary duty under ERISA.

Dave sees the future of healthcare as being local, open and decentralized. All health care is local, but financial players have inserted themselves into the equation, taking some portion of the payment for the services out of the local community. Health care needs to be more open in order to create new solutions to problems in a market dominated by a handful of payors and a relatively small number of integrated delivery systems. Dave finds inspiration in the community of craft brewers who have managed to survive and thrive in the face of almost overwhelming market power of a couple of players by sharing information openly with each other. In addition to openness, craft brewers bear the hallmark of decentralization. Small actors like craft brewers — direct primary care practices, for example — are able to replicate successes rather than scale them. Since these new success stories are decentralized, they do not necessarily appeal to traditional venture capitalists, who look for scalability rather than replicability.

Dave observes that framing an issue as a political problem virtually ensures that nothing will change: folks line up along predictable battle lines and dig in for the duration. His goal is to frame issues as local issues, as employer issues, as issues that can be solved by benefits consultants with their consciousness raised, certified by the Health Rosetta Institute. This small band of benefits consultants now represent four million lives. He sees employers’ current investment in health benefits as being no better than investing in toxic mortgages. We have a system wherein clinicians are mopping up the floor, while the spigot is still turned on full blast. There is no way to improve the situation without turning off the spigot. Five years from now, Dave hopes to have ten times as many lives represented by a growing cohort of certified benefits consultants. These consultants are the vanguard who can begin to turn the supertanker.

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http://feeds.healthblawg.com/~/500272584/0/healthblawg.html/feed0Interview,Harlow on Healthcare,Healthcare Innovation,Health Reform,Health care policy,Health Law,Health Insurance,PodcastDave Chase, co-founder of the Health Rosetta Institute, is seeking to identify and scale successes in health care that deliver on the Quadruple Aim. He is focused on the current state of the healthcare industry as an “extractive” industry, and the need to change it by changing health care benefits and services purchasing behavior among the country's employers. As he puts it, we didn't get better lighting by optimizing oil lamps.
The current evolution of Dave's thinking is captured in his recent book, CEO's Guide to Restoring the American Dream: How to Deliver World Class Health Care to Your Employees at Half the Cost (available via the Health Rosetta Institute website). In his view, we need to rationalize health benefits purchasing in order to stop the unceasing increases in spending with no increase in quality or value. There is a profound disconnect between price and value, and there is significant overtreatment of individuals. On the pricing front, many employer-based health plans seem content to pay just about whatever the providers charge, while better-managed plans focus on reference-based pricing (say, 140% of Medicare fee schedule). Some would say that, as individual employees have more and more responsibility for health care costs, the self-insured employer health plans' failure to better manage health care spending is a massive breach of fiduciary duty under ERISA.
Dave sees the future of healthcare as being local, open and decentralized. All health care is local, but financial players have inserted themselves into the equation, taking some portion of the payment for the services out of the local community. Health care needs to be more open in order to create new solutions to problems in a market dominated by a handful of payors and a relatively small number of integrated delivery systems. Dave finds inspiration in the community of craft brewers who have managed to survive and thrive in the face of almost overwhelming market power of a couple of players by sharing information openly with each other. In addition to openness, craft brewers bear the hallmark of decentralization. Small actors like craft brewers — direct primary care practices, for example — are able to replicate successes rather than scale them. Since these new success stories are decentralized, they do not necessarily appeal to traditional venture capitalists, who look for scalability rather than replicability.
Dave observes that framing an issue as a political problem virtually ensures that nothing will change: folks line up along predictable battle lines and dig in for the duration. His goal is to frame issues as local issues, as employer issues, as issues that can be solved by benefits consultants with their consciousness raised, certified by the Health Rosetta Institute. This small band of benefits consultants now represent four million lives. He sees employers' current investment in health benefits as being no better than investing in toxic mortgages. We have a system wherein clinicians are mopping up the floor, while the spigot is still turned on full blast. There is no way to improve the situation without turning off the spigot. Five years from now, Dave hopes to have ten times as many lives represented by a growing cohort of certified benefits consultants. These consultants are the vanguard who can begin to turn the supertanker.
I spoke with Dave as part of my ongoing series of fireside chats with healthcare innovation leaders – Harlow on Healthcare, on HealthcareNOW Radio. You can catch me live weekdays at 8:30 am, 4:30 pm and 12:30 am. As each new show goes live, the last one joins the archive, available via SoundCloud or your favorite podcast app (iTunes, Stitcher). Your comments are welcome here. Join the conversation on Twitter at #HarlowOnHC.
David Harlow
The Harlow Group LLC
Health Care Law and Consulting Dave Chase, co-founder of the Health Rosetta Institute, is seeking to identify and scale successes in health care that deliver on the Quadruple Aim. He is focused on the current state of the healthcare industry as an “David Harlow